The Supreme Court did not see the issue in Tiger Global as an isolated dispute over taxation. It viewed the issue against the broader backdrop of treaty interpretation and the play of sovereign powers.

The proposed Section 28A of the Bill is a practical step toward resolving the long-standing problem of fragmented enforcement of third-party security and directly addresses the deadlock seen in Vistra ITCL.

The Directions mark an important shift away from static authentication to stronger, risk-aware controls.